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3.3 Coherence and Effectiveness Tests
Test
CE1: The plan sets out a coherent strategy from which its policies and allocations logically flow and where cross boundary issues are relevant is it in conflict with the plans of neighbouring Councils.
CE2: The strategy, policies and allocations are realistic and appropriate having considered the relevant alternatives Comments
The draft Plan Strategy is clearly set out and comprises two parts, Part 1 sets out the Strategic Spatial Policies and association policies and Part 2, which sets out the General Policy and the Strategic Subject Policies. Page 21 of the draft Plan Strategy outlines the structure of the document, and illustrates how it flows from the vision, to the strategic objectives, to the Spatial Growth Strategy, to the Strategic Spatial Proposals, through to the General Policy and the Strategic Subject Policies. The vision was based upon that of the Council’s Community Plan, in that it aspires to improve the quality of life for everyone, and the strategic objectives were designed to assist in the delivery of the visions of both the LDP and Community Plan. The LDP Spatial Growth Strategy will help support the realisation of the strategic objectives by broadly setting out where growth should be directed in terms of housing, employment and commercial development over the plan period. In turn, the Spatial Growth Strategy will be primarily delivered through the Strategic Spatial Proposals and Strategic Subject Policies.
The LDP Spatial Growth Strategy is a balanced approach which takes account of the evidence base and will help achieve the RDS objectives of promoting growth and economic development opportunities in the ‘main hubs’ of Ballymena and Larne and support the role of Carrickfergus within the Belfast Metropolitan Urban Area, whilst sustaining rural communities living in smaller settlements and the open countryside allowing them to maximise their potential.
The LDP Spatial Growth Strategy has informed both the allocation for housing through SGS3 Strategic Housing Allocation Strategy and the allocation for economic development through SGS6 Strategic Allocation of Land for Economic Development, both of which have the principal focus for development within Ballymena, Larne and Carrickfergus.
The Technical Supplements illustrate a clear logical flow of consideration of each stage of the LDP process, and how this has informed the formulation of the policies within the draft Plan Strategy.
As part of the consideration of potential cross boundary issues Council has taken account of the plans from the three neighbouring Councils, which are at varying stages of the LDP process. Council has considered cross boundary issues throughout the LDP process and this is documented within the ‘Cross Boundary Policy Context’ within the Technical Supplements, which included meetings with officials from adjoining Councils prior to the publication of the draft Plan Strategy to discuss our strategic proposals and policies to enable them to consider any implications for the emerging draft Plan Strategy. Council does not consider the draft Plan Strategy to be in conflict with the plans of neighbouring Councils. In their responses to the draft Plan Strategy consultation the neighbouring Councils did not raise any conflicts with their own plans. See DPS-117 –DPS-141
Prior to publication of the Preferred Options Paper, Council gathered an evidence base that included information and data on the social, economic and environmental characteristics of the Borough and engagement with a range of statutory consultees, council officials and Elected Members. Generally, the strategic planning issues identified in the Preferred Options Paper either emerged from the evidence base or engagement. The evidence base was published alongside the Preferred Options Paper in a series of position papers. See DPS-508 –DPS-529
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Evidence
and are founded on a robust evidence base.
CE3: There are clear mechanisms for implementation and monitoring.
CE4: The plan is reasonably flexible to enable it to deal with changing circumstances.
The process of gathering and updating evidence and engagement continued during preparation of the draft Plan Strategy, and a series of topic based Technical Supplements were published for the formal consultation of the draft Plan Strategy. The Technical Supplements build upon and update the previously published position papers, and illustrate how the various strands of the evidence base were considered in the formulation of strategic proposals and subject policies, including responses to the Preferred Options Paper and the ongoing consultee and councillor engagement.
Alternatives to Preferred Options were presented in the Preferred Options Paper, and the draft Plan Strategy Technical Supplements outline how proposals and policies evolved including where alternative approaches were considered. In addition, reasonable alternatives were considered as part of the SA/SEA carried out for the Preferred Options Paper and the draft Plan Strategy. See DPS-117 –DPS-141
See DPS-106, DPS107, DPS-503 and DPS-504
The Planning Act (Northern Ireland) 2011 requires Council to submit an annual monitoring report (AMR) to DfI to indicate the extent to which the objectives set out in the LDP are being achieved. Technical Supplement 1 sets out Council’s approach to the AMR, which focuses on the LDP objectives and assesses the extent to which they are being achieved through the policies and proposals set out in the LDP.
The AMR will be flexible to include new or revised indicators to allow for better monitoring in circumstances where new data and information becomes available. Trends emerging from successive AMR’s will indicate whether the LDP policies and proposals are achieving their objectives and if it becomes apparent this is not the case Council will consider potential corrective actions, before initiating a formal review of the LDP. To inform the AMR, Council will continue to carry out its annual Housing Land Availability (housing monitor) and biennial Industrial and Economic Land Monitor. See DPS-116
Ongoing monitoring as outlined above under CE3 will provide opportunities to deal with changing circumstances, which could include a revision to the LDP to replace or amend a policy. In addition to the AMR Council is required to carry out a plan review every 5 years following adoption of the Local Policies Plan that provides a further opportunity to make amendments to the LDP.
Paragraph 1.7.1 of the draft Plan Strategy highlights whilst the LDP when adopted in full will assume primary importance in the determination of planning applications, that other material planning considerations may be afforded some degree of weight, depending on the circumstances of each case, which provides flexibility in the assessment of material planning considerations.
Whilst planning policy cannot cater for every proposal or development, Policy GP1 The General Policy for all Development applies to all forms of development (except minor proposals) and provides operational policy for specific forms of development which are not specifically catered for through the strategic subject policies. This provides flexibility by providing a policy basis for the assessment of new types of development which may occur during the plan period. See DPS-116
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